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    <title>2015 (8) TMI 42 - ITAT DELHI</title>
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    <description>The revenue&#039;s appeal, seeking to uphold the addition made under section 2(22)(e) as deemed dividend, was dismissed. The Tribunal held that the provisions of section 2(22)(e) could not be invoked as the recipient company was not a shareholder of the lending company. Additionally, the assessee&#039;s cross-objection regarding partial disallowance under section 40(a)(ia) was allowed for statistical purposes. The Tribunal directed the Assessing Officer to verify if the impugned payments were included in the recipients&#039; income computation, taxes were paid, and returns were filed, and to decide the matter afresh.</description>
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    <pubDate>Wed, 29 Jul 2015 00:00:00 +0530</pubDate>
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      <title>2015 (8) TMI 42 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=262125</link>
      <description>The revenue&#039;s appeal, seeking to uphold the addition made under section 2(22)(e) as deemed dividend, was dismissed. The Tribunal held that the provisions of section 2(22)(e) could not be invoked as the recipient company was not a shareholder of the lending company. Additionally, the assessee&#039;s cross-objection regarding partial disallowance under section 40(a)(ia) was allowed for statistical purposes. The Tribunal directed the Assessing Officer to verify if the impugned payments were included in the recipients&#039; income computation, taxes were paid, and returns were filed, and to decide the matter afresh.</description>
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      <pubDate>Wed, 29 Jul 2015 00:00:00 +0530</pubDate>
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